DEPARTMENT: Ethics and Compliance
POLICY DESCRIPTION: Self-Reporting of
Violations of Certain Laws and Regulations
PAGE: 1 of 1
REPLACES POLICY DATED:
EFFECTIVE DATE: February 11, 1998
REFERENCE NUMBER: EC.003
APPROVED BY: Ethics and Compliance Policy Committee
SCOPE: All Company facilities, including but not limited to hospitals, ambulatory surgery
centers, home health agencies, and physician practices, and all Corporate departments.
PURPOSE: To establish a process to address potential violations and to report to the
appropriate governmental agencies violations of laws or regulations, that occurred prior to
December 31, 1997, requiring the return of prior payments to the government.
POLICY: The Company will report to appropriate governmental agencies any violations of law
or regulation that require the return of prior payments and make any refund that is necessary.
PROCEDURE:
1.
Anyone with knowledge of a potential violation of law or regulation occurring prior to
December 31, 1997 that may require the return of any prior payments should forward to
Operations Counsel all information related to the potential violation with as much
specificity as possible regarding the type of problem, the date and place of occurrence and
the dollar amount involved.
2.
Operations Counsel will promptly collect, assemble and assess all information relating to
the potential violation and will consult with Corporate Litigation Counsel.
3.
Operations and Corporate Litigation Counsel will determine whether a violation occurred
and, if so, whether the information relating to the violation appears to be within the scope
of an on-going governmental investigation.
4.
If it is determined that the violation falls within the scope of an on-going investigation,
Outside Legal Counsel will present to the government relevant information pertaining to
the violation. Such information will be provided to the government without any payment,
in anticipation that any payment due will be included in negotiations regarding the
resolution of the investigation.
5.
If Operations Counsel and Corporate Litigation Counsel determine that a violation occurred
that does not appear to be within the scope of an on-going investigation, Operations Counsel
will report to the government and pay the government any amount due as a result of the
violation.
6.
This policy does not change or modify any provision of any Company policy adopted after
January 1, 1998, including but not limited to, the adjustments of claims through the
auditing and rebilling process.
Implementation Guidelines
EC.003 Self-Reporting of Violations of Certain Laws and Regulations
Introduction:
These implementation guidelines are intended to assist in assembling the proper documentation
when a potential violation of law or regulation requiring the return of prior payments to the
government has been identified.
Process:
1. Anyone with knowledge of a potential violation of law or regulation occurring prior to
December 31, 1997 and requiring the return of prior payments to the government should
complete paragraphs 1 through 3 of the EC.012 Implementation Guidelines and forward the
collected information to Operations Counsel.
2. Legal Operations Counsel, in consultation with Litigation Counsel, will determine if the
potential violation is within the scope of an ongoing governmental investigation.
3. If the violation is covered by an ongoing investigation, the information provided in paragraph
1 above will be forwarded by Operations Counsel to Roger Goldman, Latham & Watkins,
1001 Pennsylvania Ave., N.W. Suite 1300, Washington, D.C. 20004-2505.
4. If the violation is not covered by an ongoing investigation, Legal Operations Counsel will
complete the self-reporting process as outlined in EC.012 Implementation Guidelines.
Attachment to EC.003